Packaging waste responsibilities

It is important to understand the system of shared responsibility throughout the supply chain of packaging and to understand the packaging flow from raw material manufacturer to end-user consumption.

Stage 1
The process begins with the manufacturer of raw materials (e.g. plastic granules, steel sheet).

Stage 2  
Following raw material manufacturer, the next stage in the packaging flow is taken up by the converter who will convert the raw materials into packaging (e.g. plastic granules blow moulded into plastic bottles or steel being converted in steel cans).

Stage 3 
The next stage in the supply chain following conversion is a pack filling activity of the packaging supplied by the converter (e.g. plastic bottles filled with a beverage or steel cans filled with foodstuff).

Stage 4 
The filled packaging is then transported to the retailer who acts as the seller when selling the packaged goods to the final user or consumer of the packaging.

Alternatively 
The other scenario is for all the activities of the packaging flow to occur abroad before being imported for final consumption. For imported products, the company taking ownership when it comes through customs is considered the producer and must take the rolled up obligation for the activities that happened prior to import into the UK. For exported products, the packaging must be reported but it does not have the targets applied.

Therefore, to handle packaging that makes up the packaging flow means to carry out one or more of the following activities:

Supply packaging raw materials that you have manufactured
Supply packaging that you have converted from raw materials
Supply packed/filled products to retailers
Supply packed/filled products to end users or consumers
Import packaging or packaging material

The above four main stage activities share 100% of the responsibility for the packaging. The Raw Material Manufacturer takes 6%, the convertor takes 9%, the pack/filler takes 37% and the seller takes 48%. Therefore, each bit of packaging that ends up in the UK waste stream will have had 100% responsibility applied through the supply chain. 

Smaller producer allocation method

The small producer allocation method enables “small producers” (i.e. businesses handling more than 50 tonnes of packaging and with a turnover between £2 million and £5 million) to choose to have a recycling obligation allocated to them rather than having to collate and provide data each year to the Agency and calculate their own obligations.

The allocation is based on the company’s turnover in the previous year and recycling is to be carried out in the main material handled. The allocation method is voluntary, but if this approach is chosen, it must be adhered to for at least 3 years (providing the turnover of the business remains under £5 million).

The tonnage allocations per £1 million turnover can be advised by Comply Direct for which evidence must be provided in the form of PRNs and/or PERN. For 2009, the figure is set at 28 tonnes per million pounds of turnover. Therefore, a company that had a turnover of £3.2m in their last accounts would have an obligation of 89.6 tonnes rounded up to 90. This would be in the predominant packaging material handled by the company. This clearly offers administrative benefits to obligated companies with a turnover between £2 and £5 million and is the much preferred option for such companies, but it must be noted that this might not lead to a lower obligation than if a company met its obligation by using the full producer method of calculation.